Green Belt Alliance update May 2023

Green Belt Alliance update May 2023

Planning Workshop Reminder

Thank you to those who have already signed up for our AGM and Planning Workshop in Edinburgh on 25 May 2023. The invitation to attend is for members and/or anyone interested in our work. Details of the various plans for the day can be found on our AGM page. Please contact Nina on info@aprs.scot if you have any questions about the AGM.

Image showing Duncan Campbell
Duncan Campbell 1935-2023

We were sad to learn that Duncan Campbell, a long-time APRS supporter, volunteer and member of the Executive Committee had died at the end of April. As some of you know, Duncan was the original instigator of the APRS Green Belt Alliance having initially become concerned about the massive erosion of the Edinburgh Green Belt which he both documented and campaigned against for many years. He put an immense amount of time and effort and great expertise into the project – both in a supervisory capacity and also responding to policy consultations, planning cases and commenting on proposed LDPs. In recent years he contributed to APRS’s input at the various stages of consultation that led up to the final version of NPF4 – always focused on achieving better protection for Green Belt areas. A longer appreciation of Duncan Campbell written by John Mayhew can be found on our news pages.

New Local Development Plan (LDP) Regulations and Guidance

Regulations required for producing new-style LDPs are now being scrutinised by the Scottish Parliament and will come into force on 19 May 2023. They are contained in a Scottish Statutory Instrument (SSI) 2023/101. More detailed guidance for local authorities on producing LDPs will be published soon after 19 May. The guidance seemingly contains most of the amendments made after the consultation carried out last year.

New LDPs will have a 10-year span and sit alongside NPF4, together forming the Development Plan, so won’t have to reiterate national planning policy in the way previous LDPs did. The process will involve evidence gathering to produce an Evidence Report, which has to go through a new GateCheck process by Scottish Government before the planning authority can produce a Proposed Plan.

The SP’s Local Government, Housing and Planning Committee recently took evidence on the regulations from the new Minister for Local Government Empowerment and Planning, Joe FitzPatrick MSP and Scottish Government officials during which the Minister emphasised the importance of front loading community involvement in developing new plans i.e. in the evidence gathering phase. Scottish Government intend to publish ‘fairly shortly’ separate statutory guidance on effective community engagement in development plans.

The Minister said that he expected Planning Authorities to take around 5 years to develop plans but that this would be phased and not all happening at once and around 6 Authorities are ‘ahead of the game’. These 6 were said to include Loch Lomond & The Trossachs National Park, Midlothian and Fife.

LDPs already under preparation where the Proposed Plan had already been publicly advertised by 12 February 2023 can proceed under the old system.

More regulations dealing with how LDPs can be amended during the 10-year span are to be drafted soon. This could allow a means for proposals contained in Local Place Plans that are completed and registered after the LDP is drafted to be taken forward.

NPF4 implementation – Caldwell Estate Appeal Decision PPA-220-2076

A recent appeal decision may be of interest as an indicator of how Reporters are interpreting policy in NPF4. The Planning Appeal was dismissed on the grounds that the assisted living development of 122 bungalows and 51 flats in the grounds of the listed building would have unacceptable impacts. An associated appeal for listed building consent (LBA-220-2002) was upheld.

With references to NPF4 the main reasons given for turning down the development were on sustainability grounds given the rural location, eg it would generate too much car traffic and such developments should be directed to existing settlements. The notification letter also made references to Green Belts – mainly raising the lack of clarity as to whether enabling development (such as was proposed here to fund restoring the listed Caldwell House) is considered suitable in a GB location. Concerns over loss of woodland were also detailed.

Maggie’s Bridge petition

One of our GBA supporter’s has asked if we could publicise their petition to save a historic bridge over the Monkland Canal in their local area of Green Belt at Woodhall & Faskine. Maggie’s Bridge was originally a waggon-way bridge dating from 1794 which has recently been closed off due to disrepair with resultant access problems. If you would like to help add your name the “Save Maggie’s Bridge” petition.

NPF4 implementation – Appeal Called in by Scottish Ministers

We were recently notified by the DPEA that several ongoing planning appeals over proposals for housing on Green Belt areas (including at Ferniehill in Edinburgh and Blairforkie in Stirling) have been paused following the “calling-in” by Ministers of a similar appeal (PPA-400-2147) in West Lothian at Mossend, near West Calder. This case, which relates to a proposal for 250 houses on a greenfield site in the Livingston Countryside Belt, raises issues over the operation of NPF4 and housing policy, and the Ministers’ decision will likely have implications for other cases. This will likely mean a delay of several months or more before the paused Appeals are decided.

Local Living and 20 Minute neighbourhoods – planning guidance: consultation

The Scottish Government are consulting on the above guidance which is intended to support the implementation of NPF4. The guidance is intended to assist and support planning authorities, communities and others with an interest in local living and 20 minute neighbourhoods. It is expected to be of particular relevance in the preparation of Local Development Plans (LDPs), Local Place Plans (LPPs) and to support planning decision making. Planning authorities are expected to consider how the guidance can be applied in a proportionate and place-based way and to use their discretion in deciding which components of the advice are relevant to their processes. The consultation runs until 20 July 2023. A variety of case studies are detailed from Aberdeenshire, Shetland, Edinburgh, East Ayrshire and Loch Lomond & The Trossachs National Park.

Please contact nikki@aprs.scot if you have any questions about the above or any other Green Belt related questions.

Best wishes


Green Belts Alliance Manager, APRS (Association for the Protection of Rural Scotland)

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